Reynolds v. Sims: Supreme Court Case, Arguments, Impact

In Reynolds v. Sims (1964) the U.S. Supreme Court ruled that states must create legislative districts that each have a substantially equal number of voters to comply with the Equal Protection Clause of the Fourteenth Amendment. It is known as the "one person, one vote" case. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities.

Facts of the Case

On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. Without reapportionment, multiple districts were severely underrepresented. Jefferson County, with a population of more than 600,000 received seven seats in the Alabama House of Representatives and one seat in the Senate, while Bullock County, with a population of more than 13,000 received two seats in the Alabama House of Representatives and one seat in the Senate. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment.

In July 1962, the United States District Court for the Middle District of Alabama acknowledged the changes in Alabama’s population and noted that the state legislature could legally reapportion seats based on population, as was required under Alabama’s state constitution. The Alabama legislature convened that month for an “extraordinary session.” They adopted two reapportionment plans that would take effect after the 1966 election. The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. The second plan was called the Crawford-Webb Act. The act was temporary and would only be put in place if the first plan was defeated by voters. It called for a 106-member House and a 35-member Senate. The districts adhered to existing county lines.

At the end of July 1962, the district court reached a ruling. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. The district court drafted a temporary re-apportionment plan for the 1962 election. The state appealed the decision to the Supreme Court.

Constitutional Questions

The Fourteenth Amendment guarantees equal protection under the law. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Can a state use a reapportionment plan that ignores significant shifts in population?

Arguments

The state argued that federal courts should not interfere in state apportionment. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. They were based on rational state policy that took geography into account, according to the state's attorneys.

Attorneys representing the voters argued that Alabama had violated a fundamental principle when it failed to reapportion its house and senate for close to 60 years. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. The district court had not erred in its finding that neither the Crawford-Webb Act or the 67-member plan could be used as a permanent reapportionment plan, the attorneys argued.

Majority Opinion

Chief Justice Earl Warren delivered the 8-1 decision. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. The U.S. Constitution undeniably protects the right to vote. It is “of the essence of a democratic society,” Chief Justice Warren wrote. This right, “can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise.” Alabama diluted the vote of some of its residents by failing to offer representation based on population. A citizen’s vote should not be given more or less weight because they live in a city rather than on a farm, Chief Justice Warren argued. Creating fair and effective representation is the main goal of legislative reapportionment and, as a result, the Equal Protection Clause guarantees the "opportunity for equal participation by all voters in the election of state legislators."

Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. States may have to balance representation based on population with other legislative goals like ensuring minority representation. However, states should strive to create districts that offer representation equal to their population.

Chief Justice Warren wrote:

“Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests. As long as ours is a representative form of government, and our legislatures are those instruments of government elected directly by and directly representative of the people, the right to elect legislators in a free and unimpaired fashion is a bedrock of our political system.”

Dissenting Opinion

Justice John Marshall Harlan dissented. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. Despite claims of the importance of "equality," the language and history of the Fourteenth Amendment suggest that it should not prevent states from developing individual democratic processes.

Impact

Post-Reynolds, a number of states had to change their apportionment plans to take population into account. The reaction to the decision was so strong that a United States senator tried to pass a constitutional amendment that would allow states to draw districts based on geography rather than population. The amendment failed.

Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. In 2016, the Supreme Court rejected a challenge to “one person, one vote” in Evenwel et al. v. Abbott, Governor of Texas. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority.

Sources

• Reynolds v. Sims, 377 U.S. 533 (1964).
• Liptak, Adam. “Supreme Court Rejects Challenge on One Person One Vote.” The New York Times, The New York Times, 4 Apr. 2016, https://www.nytimes.com/2016/04/05/us/politics/supreme-court-one-person-one-vote.html.
• Dixon, Robert G. “Reapportionment in the Supreme Court and Congress: Constitutional Struggle for Fair Representation.” Michigan Law Review, vol. 63, no. 2, 1964, pp. 209–242. JSTOR, www.jstor.org/stable/1286702.
• Little, Becky. “1960s Supreme Court Forced States to Make Their Voting Districts Fairer.” History.com, A&E Television Networks, 17 June 2019, https://www.history.com/news/supreme-court-redistricting-gerrymandering-reynolds-v-sims.